SanctionsLookup

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OFAC Enforcement Actions in 2022

OFAC published 16 civil penalties and settlements in 2022, totaling $42.7 million, more than twice the 2021 total of $20.9 million (20 actions). The largest 2022 OFAC penalty was $24.3 million against Bittrex, Inc. Amounts are OFAC civil penalties only, excluding related DOJ, Federal Reserve, and state resolutions.

  • Total penalties$42.7Mvs 2021: $20.9M
  • Total actions16vs 2021: 20
  • Largest penalty$24.3Mvs 2021: $8.6M

2022 OFAC Penalties

NameProgramView
1612/30/2022
Danfoss A/SMachinery & Equipment
iransudan+1
$4,379,810
1511/28/2022
Payward, Inc. d/b/a KrakenCrypto
iran
$362,159
1410/18/2022
Nodus International Bank, Inc.Banking
reportingvenezuela
-
1310/11/2022
Bittrex, Inc.Crypto
cubairan+3
$24,280,829
129/30/2022
Tango Card, Inc.Payments
cubairan+3
$116,049
119/26/2022
CFM Indosuez WealthSecurities
cubairan+1
$401,039
109/26/2022
CA Indosuez (Switzerland) S.A.Securities
cubairan+3
$720,258
97/21/2022
MidFirst BankBanking
wmd
-
87/15/2022
American Express National BankBanking
kingpin
$430,500
75/27/2022
Banco Popular de Puerto RicoBanking
venezuela
$255,938
64/25/2022
Toll Holdings LimitedLogistics
irannorthkorea+3
$6,131,855
54/21/2022
Newmont CorporationMining
cuba
$141,442
44/21/2022
Chisu International CorporationTrading
cuba
$45,908
34/1/2022
S&P Global, Inc.Securities
russia
$78,750
21/11/2022
Sojitz (Hong Kong) LimitedTrading
iran
$5,228,298
11/3/2022
Airbnb Payments, Inc.Payments
cuba
$91,172

2022 OFAC Enforcement by the Numbers

OFAC resolved 14 of its 16 enforcement actions in 2022 through settlements. The median penalty was $381,599. Enforcement was concentrated in the second half of the year, with 7 actions in the first half and 9 in the second, including 5 in the third quarter.

Iran-related sanctions were cited in 8 of the 16 actions, Cuba in 7, Syria in 6, Russia in 4, and Sudan in 3. Banking accounted for 4 actions, and securities accounted for 3 actions. All 16 actions targeted companies.

By total penalties, 2022 ranks 11th of the 20 years in this database, and 17th by number of actions. For the 13 cases where OFAC published a base penalty, OFAC's calculated base penalties totaled $536 million; those parties ultimately paid $42.6 million, an aggregate 92% reduction.

OFAC Enforcement Actions by Year